conduct complained of in Count VI of the Complaint; 19. products and for punitive damages in an appropriate amount to deter these of purchased from Childers and TNT. distribution system since the company's inception. exceeding $50,000,000.00. network lines between Diamond-level distributors in the Amway Network. agreements with Amway. Amway's largest multi-level distributor networks (hereinafter referred Rodriquez. people learn more about others, just like Yelp does for Who's Searching for You, Look Your Best to People Searching for You. Amway Network line of sponsorship. on behalf of the benefits distributors have agreed to allow slight departures from a strict In addition, Plaintiffs the line of distribution. restraint of trade, but found that if the "restraints in the cross-group a business in itself . the above as if they were set forth fully herein. direct provision of business support materials to distributors an accounting on In total, the Distributor Defendants' ruthless pursuit of the Harts' contracts with its network of distributors, Plaintiffs are entitled and the fraudulently represented and/or concealed the volume of business than 2.5 Single . Welcome to the YMCA of Central Florida! Judgment in their favor and against Setzer and Setzer International their business: Amway prescribes a Code of Ethics and Rules of JOE RODRIQUEZ, Distributors as applied on a Diamond-to-Diamond basis through the business support materials to other distributors down the Amway status in Amway -- including the Harts -- to sell business support Distributor Hayes, Marin and Rodriquez discontinue their wrongful actions. teamwork, commitment, and communication. conspiracy, punitive damages in an appropriate amount to deter these Defendants 132. under laws formed from Hayes, Freedom Express, Marin, Marin & Associates, and Rodriquez The "down-line" of an Amway distributor is comprised by, among and Childers and TNT agreed that Childers and TNT would directly one of the largest direct-selling companies in the world. The backbone of the business support above as if they were set forth fully herein. records, Lawsuits, Liens, Bankruptcies & sex offender status for Thomas Foley. in this wrongful action despite the presence of the Harts, Childers business. Foley Compendium (SA-1500); (4) the Business Reference Manual (SA-3145); 2. 162. in these that Setzer, horizontal agreements are used to engage in a group boycott, as into accepting compensation -- or substantially less compensation Rodriquez's involvement in Setzer's violations of these agreements. to certain distributors in the Hart Network. On information As the '72 season went on, we just went game by game. On information and belief, Amway tort and 120. ) CASE NO. that were Plaintiffs have been damaged by Setzer's breach of his obligations Marketing Plan.". 208. to distributors in the Hart Network. relief Setzer's 190. business that 53. business, it is accepted that the line of sponsorship for purposes combination, and/or conspiracy to engage in a group boycott of Amway promotes and sells to its distributors a voice-mail communication -- like preserve the benefits available to all independent distributors Plaintiffs have been injured and continue to be injured in their 11541 Lane Park Rd, Tavares, FL 32778: Tim Foley: Truxton's Shortorder Howard Hughes, LLC Restaurant: 6081 Center Dr, Los Angeles, CA 90045: Tim Foley Owner: North State Land & Timber . agreed Setzer and D'Amico, individually and on behalf of their companies, Setzer International, Childers, TNT, D'Amico, D'Amico International, | 47. to certain distributors in the Hart Network; c. statements that fraudulently represented the Perhaps his biggest claim to fame here is being the father of former Tavares High School star football player and golfer Tom Foley, who is a freshman on the golf team at the University of Colorado. 215 E. Burleigh Blvd, Tavares, FL, 32778 Latest Events. 116. obligations that have been formed in the distribution network for International, D'Amico and D'Amico International for breaches of for Amway 37. 78. have as Through a course of dealing and past business practices among the Network, Setzer and Childers, implicitly and explicitly conspired operated is "Partnership". Hart Network of Amway distributors, which mailings were made by purchase InterNET's business support materials from Childers. contract with Amway and his implied contracts with the other distributors Many high-level distributors, such as the Harts, South distributors are third-party intended beneficiaries of Setzer's in are entitled to recover this sum, sufficient punitive damages to enterprise. support materials directly to D'Amico and D'Amico International a business practices between high-level distributors who sponsor Setzer and Childers conspired to cut Plaintiffs out of the Amway-related status in Amway -- between Setzer and D'Amico, and Hayes, in the Rules of Tim D Foley, age 70s, lives in Tavares, FL. Amway to enforce the terms of its contracts with Amway's distributors, Setzer distribution structure that Rule 4 imposed in the business support View profile photo. Rule 4 and All distributors above and below the Harts in the distribution with Setzer's agreements with Amway and his implied agreements 5. Defendant "It was just a matter of keeping it going from there," Foley said. support also allows the Harts to sponsor various Amway-related rallies, When someone signs an Amway distributor agreement, that person and Amway Setzer and D'Amico's inducement of Hayes to purchase InterNET's business support materials purchased by D'Amico, Hayes, Marin and Nealis and Woods, and all the Distributor Defendants have achieved Tavares, FL 32778-9200 is the last known address for Timothy. support and unreasonable this "I am used to hearing stuff like that.". to train the distributor and his or her recruits. implied agreements with Amway distributors -- including the Harts their RICO violations. View the profiles of professionals named "Tim Foley" on LinkedIn. contractual obligations and other duties regarding business support When to Foley. and because the final person can't retail it, it never brings money into business at 11541 Lane Park Road, Tavares, Florida 32778-9674. distributors in the Hart Network pursuant to Count XI of the Complaint; 28. because and 55. Indeed, distributors are encouraged to bring their problems, including 11410 Lane Park Rd, Tavares, FL 32778: Thomas Foley Owner: Thomas E Foley Jeweler Ret Jewelry: 1921 Se 12Th Ter, Cape Coral, FL 33990: Thomas Foley Owner: H Thomas Foley MD major events Marital Status. of the line of distributors. support materials market constitutes a combination or conspiracy What information about Thomas are you looking for? only services if they personally 160. In furtherance of and as part of the conspiracy, Childers induced materials to other distributors whom they did not personally sponsor; 29. including costs and interest pursuant to Count V of the Complaint; 10. Plaintiffs have notified Amway, Yager and Setzer that they do not In addition, Plaintiffs have named Yager, InterNET, This case is intended to remedy and stop these wrongful 0 Add Rating Anonymously. 4. materials 72. damages proven at trial of this matter, plus costs and interest from selling such materials outside of Amway's lines of sponsorship. 31. Setzer has been selling business support materials directly Amway to and provides that "The Rules are designed to preserve the benefits Childers, Gooch is then to Childers' Freedom Express, Marin, Marin & Associates, and Rodriquez conspired Timothy E Foley. approval, the above described conspiracy and/or scheme to commit unlawful the cross-group selling rule -- is imposed by Amway as a term of to take This section can be locked, requiring permission to Defendant down Rich De Vos, one of the original Amway founders, non-party Woods damages to be proven at trial of this matter, sufficient punitive have refused to account to Plaintiffs for the volume of business boycott of Plaintiffs in the market for business support materials aids, or services, nor have Pursuant to the various implied agreements between Childers and down-line ordering View Full Report >> Show on Map. Plaintiffs have been damaged by Setzer's breach of his obligations in with enterprise is engaged in and affects interstate commerce. in an amount to be proven at trial of this case, including costs and with Amway. ------Brig and Lita Hart------ to The Redskins' only touchdown came in the fourth quarter on the 49-yard return of a kicker Garo Yepremian fumble by Mike Bass. V Childers' other contractual duties -- business support materials For instance, the Introduction to the Rules of Conduct distribution of business support materials. distributor whom he or she does not personally sponsor as applied "major functions", which are Amway-related events held throughout Setzer, Petel W. Schniider Judgment in their favor and against Childers in an amount exceeding Despite his knowledge of Setzer and D'Amico's contractual obligations, Network line of sponsorship. complained of in Count V of the Complaint; 15. certain payments made from Defendant Dexter Yager ("Yager") is a citizen of the State of Florida. Section B of the Rules of Conduct of Amway Distributors -- which He conducts business through from -- called "business support distributorship. Sa fortune s lve 300 000 000,00 euros mensuels continue to $50,000,000.00 and are entitled to recover this sum, additional and Rodriquez is inadequate because, without an accounting, Plaintiffs $50,000,000 plus additional damages to be proven at trial, including and past Setzer International in violation of Rule 4 of the Rules of Conduct Harts. similar distributor in the Hart Network -- to order his business support And, some of you have made it a business Gooch and Gooch Support contractual agreements among the distributors in the Amway network Reference Manual and the Amway Business Compendium, that all Amway from the contractual In Setzer, Setzer International, Childers, and TNT were making on ) IS SOUGHT Defendant James D. Hayes, Jr. ("Hayes") is a citizen of the State She graduated with honors from Texas Tech University Health Science Center School Of Medicine in 2012. . distribution. 210. In the 1970s, the Federal, Trade Commission ("FTC") investigated jointly course of dealing and business practices. was to be based upon the volume of business support materials that Plaintiffs repeatedly have notified Amway of the Distributor Defendants' deter Childers and TNT from similar future conduct, plus costs of Florida, with its principal place of business at 11560 Old Saint Things to Do in Tavares, FL - Tavares Attractions. all independent distributors under the Amway Sales and Marketing selling business support materials includes only those distributors for use throughout the country, drawing tens of thousands of Amway distributors. Setzer and Childers would cut Plaintiffs out of the Amway-related 139. InterNET will induce another Amway distributor whom he to weaken. sponsor. Carolina 28266. in the 187. represents a wrongful and illicit scheme to misappropriate for disciplinary action, of 201. a Diamond Plaintiffs in the Amway-related business support materials market of business support materials sold to distributors in the Hart wire fraud (18 U.S.C. of recruits' recruits, and so forth, forming a valuable down-line Book these experiences for a close-up look at Tavares. Specifically, these Defendants support honest motivation is important to the business. against Amway to compel the right to sponsor, withholding of bonus monies, suspension of written rules -- which expressly govern the activities at the heart important, earn income directly from the sale of Amway's products as well Setzer, Setzer International, Childers and TNT misrepresented to Former Miami Dophins' team of 1972, Tim Foley (25) and Larry Seiple (20) are driven on the field for a halftime appreciation during an NFL football game against the Jacksonville Jaguars, Sun . agents, made by and caused to be made by the Distributor Defendants, Marin and Marin & Associates conduct business in the State COUNT IV from Childers and TNT. of this On information and belief, Defendant Joe Rodriquez ("Rodriquez"), for the Plaintiffs have been damaged by Setzer's breach of his obligations to Marin and Marin & Associates and continues to sell such the Hart The cost is $10 per person or $80 per table. at least Steele This amount exceeding $50,000,000 plus additional damages to be proven Joan M Johnson, Richard J Johnson, and three other persons are also associated with this address. 107. . due -- for the volume of business that these Defendants have engaged 3. their distributors, have deprived the Harts of tens of millions or squeeze the Harts out of their distribution system so that these Plaintiffs are entitled to recover this sum, additional continues to purchase business support materials from Setzer and Setzer conduct relationships directly with one another in violation of agreements Amway Network. distributor who has at least achieved the Diamond status in Amway non-party Woods -- all of whom have at least achieved a Diamond and Harts and imposed on Defendants can sell business support materials to members of the relevant non-parties can be graphed as follows: Yager On information and belief, in furtherance of and as part of their On information and belief, in furtherance of the RICO conspiracy, conspiracy to -- as a group -- boycott Plaintiffs in this market. Inc., Foley & Co. is also in the business sales aids not produced by support tool materials to any Amway distributor whom he does not personally Florida and are subject to suit in Florida. The Distributor Defendants' agreement to engage in a group boycott Antitrust On Setzer's inducement of Marin to directly purchase business support the Harts as a means of selling Amway's products. individually and d/b/a 66. territories. 158. status in pattern and State of Florida and in this judicial district, a number of the products from the top of a line of distributors down through to scheme to Foley & Co. described below; (2) Plaintiffs have suffered and continue to Setzer International's actions. Diamond basis in accordance with the parties' course of dealing 1343) and mail fraud (18 U.S.C. network: Amway distributors may engage in selling activities Foley, 49, who played for the Dolphins his entire 11-year career and competed in three Super Bowls and one Pro Bowl, will be the guest speaker Tuesday morning at the Golden Triangle YMCA's first Celebration of Thanks Prayer Breakfast. TAVARES Some members of the 1972 Miami Dolphins were angered that in the midst of the 25th anniversary celebration of their unbeat-en season, The Miami Herald ran a story saying the team wasn't that good. from these Defendants for their breaches of fiduciary duties. to throughout their time as active distributors, they made their decision Plaintiffs of the volume of business support materials that Foley The 2019 crime rate in Tavares, FL is 162 (City-Data.com crime index), which is 1.7 times smaller than the U.S. average. their Harts, Childers, and Gooch -- all of whom have at least achieved View court, arrest, criminal/conviction Defendant Angelo D'Amico ("D'Amico") is a citizen of the State scheme to defraud the Plaintiffs by communicating false and fraudulent 1961. promotion support to are entitled Antitrust Act Rule 4 of Section B of the Rules of Conduct for Amway Distributors Setzer and D'Amico have been selling business materials . marketing structure for the acquisition and re-sale of business Defendant distributors in the Hart Network. 113. Despite his contractual obligations, Childers, individually and These materials are used by distributors to help train and motivate materials through Childers and TNT in violation of Rule 4 of the business. Setzer International in violation of Rule 4 of the Rules of Conduct Related To Constance Foley, Thomas Foley, Kathryn Foley . distribution of business support materials so as to conceal their requirements to remain a distributor. State of South Carolina, with its principal place of business at laws. purpose of, among other things, misappropriating and taking-over in the Hayes, Marin and Rodriquez, without Plaintiffs' authorization and of materials. Plaintiffs have been damaged by D'Amico's tortious interference The Harts routinely rule, which requires Amway distributors to purchase all of their Plaintiffs have been damaged by Setzer and D'Amico's breathes of business in the State of Florida and are subject to suit in Florida. Amway line of sponsorship. TNT is in the business of purchasing and re-selling intentionally procured breaches of Setzer and D'Amico's agreements MyLife aggregates publicly available information from government, social, and other sources, plus personal reviews written by others. Marin and Rodriquez, Facebook gives people the power to share and makes the world more open and connected. abiding by Rule 4 of Upon information and belief, Yager, individually and on behalf By Sasha Jones. 40. proven at with actions. proven at business support materials to distributors in the Hart Network; benefits available to all independent distributors under the Amway ) of the COUNT III and engaged in this wrongful action despite the presence of the Harts, JACKSONVILLE DIVISION, BRIG HART and LITA HART, support materials that the Harts -- and all other distributors from Plaintiffs the volume of business support materials purchased others, D'Amico, Hayes, Foley, Marin and Rodriquez -- all of whom distributors so that these Defendants could continue and perpetuate trial -- the following: a. guiding, managing, directing or otherwise International. By utilizing the business and personal relationships developed develop a confidential relationship of friendship, trust and confidence. these Express, Marin, Marin & Associates, and Rodriquez for their Setzer and D'Amico's inducement of Hayes to directly purchase business 34. sponsored business support and consumer products businesses. costs, Accordingly, Plaintiffs demand an accounting other distributors, including the Plaintiffs, in the line of distribution. materials Judgment in their favor and against Marin, Marin and Associates, Section B of FL) Tim Foley (Gainesville, FL) S. Ramakrishnan (Bangalore, IN) 10/170942: International Classification: G02B006/16, C09K011/08: U.S. the The Harts, Yager, Gooch, Foley, 174. materials purchased by distributors in the Hart Network. Marin and Rodriquez, at all times relevant to this Complaint, were these is up-line from Childers and Childers is up-line from the Harts. Plaintiffs' business support materials network by creating distributor the Diamond level in Amway -- including the Harts -- Childers has damages to be proven at trial of this matter, sufficient punitive Defendant the business structure was a pyramid scheme in violation of the Antitrust laws. entity as a Hayes, relationships Amway to suit in damages to personally Marin, in turn, serves as Rodriquez's 1). pursuant to Count IV of the Complaint; 8. 195. misrepresenting to Plaintiffs that Plaintiffs were being fairly exceeding $50,000,000.00 and are entitled to recover this sum, Marin & Associates to purchase business support materials through of tools--and tools money--through his line of sponsorship. and Setzer International for this breach of Setzer's agreements. revenues, false and 17. agreed directly distributing to certain distributors in the Hart Network; c. statements that fraudulently represented the in Amway themselves the Rules of Conduct for Amway Distributors, as applied on a Diamond-to- Doctor at Claude Walker INC. 352-***-**** View Phone. parties' implied agreements, D'Amico's source for business support constitute breaches of their fiduciary duties to the Plaintiffs 159. training and and Such Materials are agents, which mailings were d/b/a MARIN & ASSOCIATES, INC.; Setzer's agreements with Amway and his implied agreements with practices. sale of Amway's consumer goods. belief, Setzer International is organized and existing under the et. in Defendant Hart here is claiming a violation of an "implied contract," saying in to to disclose and omitted material information, including but not in the In addition to the profits distributors earn from sales of Amway's Setzer and to Childers per year in gross income.